Subject: File No. S7-18-09
From: Joseph Finn

August 10, 2009

I am commenting about the proposed banning of third-party placement agents from soliciting government business on behalf of investment advisors. The ban will make it more difficult for smaller investment firms. These firms generally can not hire full time marketing personnel. This gives a big advantage to the larger firms and will potentially restrict competition. I know several third party marketing firms that provide a valuable service to municipal pension sponsors and do not get involved with any "pay to play" schemes. The real issue in my opinion is full disclosure of all fees. Greater transparence and enforcement is the answer. This proposal is over-kill.